SEC and CFTC Adopt Private Fund Systemic Risk Reporting on Form PF

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The U.S. Securities and Exchange Commission recently adopted a new rule and new form under the Investment Advisers Act of 1940 to implement provisions of Title IV of the Dodd-Frank Wall Street Reform and Consumer Protection Act. The provisions require certain investment advisers registered with the SEC to file Form PF with the SEC in order to provide the new Financial Stability Oversight Council with information necessary to monitor the systemic risk created by private funds and determine whether particular entities should be designated as significant financial institutions. This update examines the new Form PF as well as some of the notable changes made to the proposed rule and form.